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The 15% minimum tax could diminish the advantage of the UAE’s 9% corporate tax rate and 0% levy on qualifying free-zone income for some large multinational groups that fall within the scope of the regime, they said.
The OECD’s Pillar 2 or global minimum-tax rules, as implemented by the UAE in January 2025, apply to multinational groups with consolidated global revenue of at least `750 million ($871 million) in two of the four preceding years, and potentially require additional tax payments when their effective rate falls below 15%. The scope of the tax can cover even relatively small UAE subsidiaries, free-zone companies and branches of large Indian groups.
Tax experts said that some Indian multinational conglomerates had been assessing their exposure and data readiness since 2024.
Several other Indian companies falling within the remit are now assessing their potential tax coverage, reassessing freezone structures and exploring available exclusions as the deadline approaches.
“We are seeing a noticeable increase in queries from large Indian multinational companies following the recent scope and compliance related guidance issued by the UAE federal tax authority,” said international tax advocate Priyanshi Chokshi. “Among them is a large pharmaceutical group with a setup in the free zone, and a large multinational group that has entities across the UAE, India, the UK, Mauritius, and the US.”Also Read: India’s gold rush takes a Dubai detour as UAE shipments soar while rest of world imports fall
The UAE ministry of finance last week specified the entities required to file the Pillar 2 Information Return. Under the UAE domestic minimum top-up tax (DMTT) regime, the revenue threshold will be tested at the group level. This means a relatively small UAE entity can fall within the rules if it forms part of a sufficiently large Indian-headed multinational group.
The qualifying firms under the top-up tax regime need to register for the levy by November 30 this year.